Case Digest (G.R. No. 189998)
Facts:
In Makati Shangri-La Hotel and Resort, Inc. v. Ellen Johanne Harper et al. (G.R. No. 189998, August 29, 2012), the petitioner operates the five-star Shangri-La Hotel in Makati City. In early November 1999, Christian Fredrik Harper, a 30-year-old Norwegian national and Business Development Manager of ALSTOM Power Norway AS, checked into Room 1428. He was due to depart on November 6 but was found murdered in the early morning of that date. His body, with eyes and mouth bound and limbs tied, was discovered after his family in Oslo received an alert from American Express about suspicious credit-card use. Hotel staff and police viewed CCTV footage showing a woman entering at 12:17 a.m. and a Caucasian man at 2:48 a.m. The victim’s passport, credit cards, laptop, and cash were missing. On August 30, 2002, respondents Ellen Johanne Harper (widow), Jonathan Christopher Harper (son), and their Philippine representative Rigoberto Gillera sued the hotel in the Regional Trial Court (RTC) foCase Digest (G.R. No. 189998)
Facts:
- Parties and Context
- Petitioner: Makati Shangri-La Hotel and Resort, Inc., owner-operator of a 5-star hotel in Makati City.
- Respondents: Ellen Johanne Harper (widow), Jonathan Christopher Harper (son), and Rigoberto Gillera (authorized representative in the Philippines).
- Murder of Christian Fredrik Harper
- Christian Harper, a 30-year-old Norwegian national, checked into Room 1428 for a business trip; scheduled to check out on November 6, 1999.
- At around 11:27 a.m. on November 6, hotel staff discovered Harper’s body bound with tape and rope; subsequent autopsy confirmed murder.
- CCTV footage showed a woman entering the room at 12:17 a.m. and a Caucasian male at 2:48 a.m., both leaving before 6:00 a.m. Harper’s passport and credit cards were later used in a Glorietta jewelry store.
- Procedural History
- August 30, 2002: Respondents filed suit in RTC, alleging gross negligence in security under Article 2176, Civil Code.
- October 25, 2005: RTC found the hotel liable; awarded ₱43,901,055.00 actual damages, ₱739,075.00 transport expenses, ₱250,000.00 attorney’s fees, plus costs.
- October 21, 2009: CA affirmed with modification; increased actual/compensatory damages to ₱52,078,702.50, added ₱25,000.00 temperate damages, maintained attorney’s fees and costs.
- August 29, 2012: Supreme Court granted review under G.R. No. 189998.
Issues:
- Did respondents present competent evidence to prove heirship (widow and son of the deceased)?
- Was petitioner’s negligence the proximate cause of Christian Harper’s death?
- Was the proximate cause instead the victim’s own negligence?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)